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Moldova: Citizenship services subject to VAT; certain interest-free loans not subject to transfer pricing rules; concurrent application of preferential tax regimes

Guidance from the State Tax Service

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february 3, 2026

The State Tax Service (STS) on December 12, 2025, clarified that legal consultancy services related to obtaining Romanian citizenship do not qualify for value added tax (VAT) exemption under article 103 (1) (6) of the Tax Code and are subject to VAT on the entire service value.

The STS on November 20, 2025, clarified that interest-free loans between affiliated Moldovan entities under the general 12% regime do not qualify as local transactions and are not subject to transfer pricing rules, though disclosure thresholds for related-party transactions still apply.

The STS also clarified that manufacturing companies may concurrently apply the regional State aid scheme and the small and medium enterprises (SMEs) tax regime. The clarification confirms a 6% income tax rate for eligible manufacturers under article 493 and a zero-income tax rate for SMEs for 2023–2025 if conditions are met, while noting exclusions for free economic zone (FEZ) residents and certain entities.


For more information, contact a KPMG tax professional:

René Schöb | rschob@kpmg.com

Inga Tigai | ingatigai@kpmg.com

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